In the case of Janet Reno, Attorney General, et al. v. Ziya K. Koray in 1994, the U.S Supreme Court ruled that a convicted offender's time spent in a community treatment center (CTC) under Bureau of Prisons' (BOP) control could be credited towards his sentence even if he was not physically confined to a cell or prison facility during this period. The court held that such confinement is considered "official detention" within the meaning of 18 U.S.C §3585(b), which allows for credit against federal sentences for any days spent in official detention prior to sentencing by order of the court where charges are pending. This decision overturned lower courts’ rulings and clarified how “official detention” should be interpreted under federal law.

In the dissenting opinion for Janet Reno, Attorney General, et al. v. Ziya K. Koray, Justice Ginsburg disagreed with the majority's interpretation of 18 U.S.C §3142(e) and (f). She argued that these provisions do not allow a district court to order detention after conviction but before sentencing unless there is a hearing as described in subsection (f). In her view, this reading was supported by both the statutory text and legislative history of the Bail Reform Act of 1984. Furthermore, she contended that even if one were to accept that post-conviction detention could be ordered without such a hearing under certain circumstances - which she did not - it would still require an explicit finding by the judge that no condition or combination of conditions will reasonably assure appearance at future proceedings or safety to any other person or community. This requirement was absent in Mr.Koray’s case; hence his detention violated due process rights guaranteed by Fifth Amendment.